Justia Utah Supreme Court Opinion Summaries

Donald Rawlings, the eldest of five siblings, claimed full ownership of farmland deeded to him by his father. Donald’s siblings sought to maintain a constructive trust over the farm property and its equal division among the children, claiming that their father never intended to vest sole ownership in Donald and to their permanent exclusion. In Rawlings I, the Supreme Court upheld a district court order imposing a constructive trust over the property in favor of the siblings under a theory of unjust enrichment. On remand, the district court permitted additional discovery to resolve the issue of what properties should be included within the constructive trust. When Donald did not adequately respond to the siblings’ discovery requests, the district court entered an order to compel. When Donald failed to comply with that order, the district court granted the siblings’ request to strike Donald’s pleadings and defenses and entered default judgment against him. The Supreme Court affirmed, holding (1) the district court did not abuse its discretion in entering default judgment against Donald; and (2) under the mandate rule, Donald may not challenge the imposition of the constructive trust. View "Rawlings v. Rawlings" on Justia Law

Plaintiffs, several employees of Wal-Mart, were involved in physical confrontations with shoplifting customers and were ultimately fired for violating company policy. Plaintiffs filed this action against Wal-Mart in federal district court for wrongful termination, alleging that terminating a person’s employment for exercising self-defense in the workplace violates Utah public policy. The federal district court certified to the Supreme Court the question of whether self-defense is a substantial public policy exception to the at-will employment doctrine, thus providing a basis for a wrongful termination action. The Supreme Court held that the policy favoring the right of self-defense is a public policy of sufficient clarity and weight to qualify as an exception to the at-will employment doctrine, but the exception is limited to situations where an employee reasonably believed that force was necessary to defend against an imminent threat of serious bodily harm under circumstances where he or she was unable safely to withdraw. View "Ray v. Wal-Mart Stores, Inc." on Justia Law

The paternal grandparents of I.J. filed a petition for visitation after the grandparents and I.J.’s mother disagreed over visitation. After a trial, the court ruled in favor of the grandparents, concluding that they had rebutted the statutory presumption “that a parent’s decision with regard to grandparent visitation is in the grandchild’s best interest,” that the grandparents had a substantial relationship with I.J., that denial of visitation had likely caused harm to I.J., and that grandparent visitation was in I.J.’s best interest. The court of appeals reversed. The Supreme Court affirmed, holding (1) a visitation order under Utah Code 30-5-2 is subject to strict scrutiny review, requiring proof that a grandparent visitation order is narrowly tailored to advance a compelling governmental interest; and (2) because there was no such proof on the record in this case, the grandparents failed to establish a legally sufficient basis for an order of visitation. View "Jones v. Jones" on Justia Law

Appellant, who worked at an oil refinery operated by Chevron U.S.A., Inc., was instructed by her immediate supervisor to add sulfuric acid to an open-air pit containing waste products from the refinery. When Appellant did so, she was injured by a poisonous gas produced by the resulting chemical reaction. Appellant received workers’ compensation benefits for her injuries. Thereafter, Appellant sued Chevron, alleging that it was liable for an intentional tort because her supervisors knew she would be injured when she was instructed to add sulfuric acid to the pit. The district court granted summary judgment for Chevron, concluding that Appellant failed to produce evidence that would support a conclusion that one of Chevron’s managers had the requisite knowledge or intent to support an intentional tort claim. The Supreme Court ruled, holding (1) there was a dispute of material fact precluding summary judgment because a reasonable jury could conclude that at least one of Chevron’s managers knew that Appellant would be injured when her supervisor instructed her to add sulfuric acid to the pit; and (2) the district court correctly ruled that the election of remedies doctrine did not bar Appellant’s suit. View "Helf v. Chevron U.S.A., Inc." on Justia Law

In 2010, the divorce court entered a decree of divorce dissolving the marriage of Charles Dahl and Kim Dahl. Kim appealed, challenging several of the district court’s rulings in the divorce case. Kim also appealed the dismissal of her claims in a separate, but related, lawsuit involving marital assets contained in the Dahl Family Irrevocable Trust. The district court consolidated, sua sponte, these cases for the purposes of appeal and remanded the consolidated case to the divorce court, holding that the Trust should have been joined as a party to the divorce action. View "Dahl v. Dahl" on Justia Law

Defendant worked for Plaintiff, a technology company, as an engineer. During and after her employment with Plaintiff, Defendant forwarded confidential emails to her private Gmail account, copied a confidential business plan to a thumb drive, and placed protected information on the record in an administrative proceeding. Plaintiff filed suit, alleging that Defendant had violated a non-disclosure agreement and misappropriated company trade secrets. The district court granted summary judgment for Defendant, determining that Plaintiff had failed to make an adequate showing of harm. The court further entered Utah R. Civ. P. 11 sanctions against Plaintiff and awarded attorney fees to Defendant. The Supreme Court reversed, holding (1) there was sufficient evidence of threatened harm - or at least genuine issues of material fact concerning such harm - to defeat Plaintiff’s motion for summary judgment; and (2) because Plaintiff prevailed on Defendant’s motion for summary judgment, Defendant could not be entitled to sanctions or fees. View "Innosys v. Mercer" on Justia Law

Plaintiff filed a public records request under the Government Records Access and Management Act (GRAMA) seeking bank records the State had legally seized during a criminal investigation. The district court denied the request, concluding that article I, section 14 of the Utah Constitution provides a broad right of privacy that prevented the State from disclosing the records. The district court also denied Plaintiff access to a summary of the bank records (the Quicken Summary) and an investigator’s handwritten notes (the Post-it Note), concluding that both documents were protected attorney work product. The Supreme Court reversed, holding (1) there can be no violation of section 14 when the government obtains information through a valid warrant or subpoena, and therefore, the bank records were not exempted from GRAMA’s public disclosure requirements; and (2) the district court correctly classified the Quicken Summary and the Post-it Note as attorney work product, but, because the State terminated its investigation years ago, the interests favoring protection were not as compelling as those favoring disclosure. View "Schroeder v. Utah Attorney General’s Office" on Justia Law

Steven Brown suffered a back injury while working as a school bus driver for the Washington County School District. Brown received workers’ compensation for this injury. In 2007, Brown was reinjured while attending a local festival. The School District denied workers’ compensation liability. An administrative law judge with the Labor Commission concluded that the prior industrial injury was a contributing cause to the second injury and awarded benefits. The Commission and court of appeals affirmed. After clarifying the causation standard under the direct and natural results test for interpreting the Workers’ Compensation Act, the Supreme Court remanded the case back to the Commission to determine whether Brown’s injury met this standard. View "Washington County Sch. Dist. v. Labor Comm'n" on Justia Law

The State sought and received an order freezing more than $3 million of Frank and Joan Steed’s assets under Utah’s Asset Preservation Statute. The State subsequently filed criminal charges against the Steeds and sought a freeze order to ensure adequate funds would be available for the anticipated restitution award. The district court upheld the freeze order. Thereafter, the Steeds were convicted of three counts of failure to file tax returns and one pattern count of criminal fraud. The Steeds later filed a motion challenging the constitutionality of the Asset Preservation Statute, both facially and as applied. The district court denied the motion. Joan subsequently conceded the issue of technical mootness but argued that the mootness exception applied. The Supreme Court dismissed the case, holding that this case was moot and that Joan’s claims did not warrant the application of the mootness exception. View "State v. Steed" on Justia Law

Employer, a steel mill, fired Employee on suspicion that Employee had misappropriated steel from the company. In firing him, Employer refused to pay Employee the commissions he claimed to have earned, asserting that it could withhold the commissions as an offset against the value of the misappropriated steel. Employee filed this action claiming that Employer had violated the Utah Payment of Wages Act (UPWA). The district court granted summary judgment for Employee, concluding that the UPWA did not permit a preemptive withholding of Employee’s commissions. The Supreme Court reversed, holding that the statute allows an employer in a case such as this one to seek a post-withholding opinion of a court or administrative law judge that an offset was warranted. Remanded for a determination whether Employer had presented evidence that in the opinion of the district court would warrant an offset sufficient to justify Employer’s withholding of Employee’s unpaid commission. View "Utley v. Mill Man Steel, Inc." on Justia Law